Document 5 Filed 01/16/14 Page 2 of 2 -2- governed by a higher standard, and require subjective bad faith on the part of the attorney. Muhammad v. Walmart Stores East. L.P., 732 F.3d 104 (2d Cir. 2013). Because Mr. Fraade is withdrawing the offending pleading without objection from the respondent within the time